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establish what petitioner's net gambling gain or loss position at
Trump Plaza Associates was at the close of his 1994 taxable year.
Therefore, petitioner has not shown that he incurred Casino
gambling losses in the amount of $50,000.
Accordingly, we hold that petitioner is not entitled to
deduct gambling losses over the $7,984 already allowed by
respondent.
II. Schedule C Expenses and Other Adjustments
The second issue is whether petitioner is entitled to deduct
certain expenses claimed on Schedule C of his 1994 Federal income
tax return. As noted above, petitioner claimed expenses on
Schedule C totaling $107,850. Respondent has fully disallowed
the Schedule C expenses, arguing that petitioner has failed to
substantiate these expenses pursuant to sections 162 and 274(d).
Deductions are a matter of legislative grace and petitioner
has the burden of proving his entitlement to them. See, e.g.,
Deputy v. du Pont, 308 U.S. 488, 493 (1940). Petitioner has
produced no evidence in connection with the deductibility of
$6,500 of "supplies" expenses, and $21,450 of "other expenses".
We therefore uphold respondent's disallowance of these expenses.
Petitioner claims $49,000 of expenses for "Taxes &
licenses". Section 164(a)(3) allows a deduction for State income
taxes paid during the taxable year. Petitioner has produced an
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